Interpretive Rules in Practice
Blake Emerson and Ronald M. Levin (Opinion published in The Regulatory Review October 30, 2019) A new ACUS recommendation on interpretive rules largely aligns with a prior one on policy statements. At its June 2019 plenary session, the Administrative Conference of the United States (ACUS) adopted Recommendation 2019-1, “Agency Guidance Through Interpretive Rules.” The recommendation…